SDLT Changes From April 2021
My clients are a non-resident married couple who have a portfolio of UK residential properties in both sole and joint ownership. As part of an Inheritance Tax planning exercise, the husband is considering the transfer of some of his properties to his wife and this will include a transfer of debt which we understand is treated as “consideration” for SDLT purposes.
Can you please explain the consequences for Stamp Duty Land Tax of transfers being done both before and after the end of the current SDLT “holiday”, both in terms of the additional 3% “higher-rate for additional dwellings” and the proposed additional 2% for acquisitions by non-residents after 31 March 2021? We expect the debt to be transferred to his wife to be below the £500,000 threshold available under the temporary SDLT “holiday”.
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